WGQ Pipeline SegmentWork Paper
NAESB WGQ Request No. R06008
January 3, 2007
Based on the NAESB WGQ Pipeline Segment ("Pipelines") comments and work papers provided duringthe subcommitte discussions related to the May 2006 request R06008 submitted by National Fuel Gas Distribution Corporation (NFGD) and during the recent Executive Committee (EC) meeting, the Pipeline Segment generally believes the standards and changes being proposed will benefit the industry from the addition of more specificity regarding the gas quality data to be posted. As indicated previously, the Pipeline Segment is supportive of efforts to clarify expectations regarding gas quality information provided on Informational Posting Web Sites. However, after significant discussion, there remain several issues on which the Segment has not been able to reach agreement with the latest NFGD proposals.
The Pipeline Segment concerns are outlined below, as well as revised and new language which can be supported by thePipelines. The draft standards shown are based on the last set of proposed standards used in the December 7, 2006 EC meeting.
Discussion - NAESB WGQ Standard No. 4.3.90
In addition to offering some minor typographical changes to NAESB WGQ Standard No. 4.3.90, the Pipelines believe that the proposed changes to the sentence prior to the gas quality attribute listing to be inappropriate. Existing language from WGQ Standard No. 4.3.90 states, "Listed below are examples of gas quality attributes that could be included in posting for the applicable Gas Day(s) and Location(s):" This language indicates that the attributes shown are a representative list that could be includedin a TSP’s posting, but are not necessarily required. To modify the existing 4.3.90 language eliminates clarity and opens up the standard for unneeded interpretation. Additionally, to provide more clarity regarding what is required to be posted prusuant to this standard, the Pipelines recommend the following language for revised Standard No. 4.3.90, including the new paragraph following the representative list of attributes.
Pipeline Segment Revised NAESB WGQ Standard No. 4.3.90
The Transportation Service Provider (TSP) should provide on its Informational Postings Web Site daily average gas quality information for prior gas day(s), to the extent available, for location(s) that are representative of mainline gas flow. The information available for the identified location(s) should be provided in a downloadable format. Information should be reported in units as specified in the tariff or general terms and conditions. In any event, all applicable parties’ compliance with gas quality requirements is in accordance with the TSP’s tariff or general terms and conditions.
The followingListed below are examples of gas quality attributes that could be included in the posting for the applicable Gas Day(s) and Location(s):
•Heating Value
•Interchangeability index(ices)/factor(s)
•Hydrocarbon lLiquid dDropo Out control parameter(s)/factor(s)
•Hydrocarbon cComponents, % of C1 – Cnn, as used in determining Heating Value
•Specific Gravity
•Water
•Nitrogen
•Carbon Dioxide
•Oxygen
•Hydrogen
•Helium
•Total Sulfur
•Hydrogen Sulfide
•Carbonyl Sulfide
•Mercaptans
•Mercury and/or any other contaminants being measured
•Other pertinent gas quality information that is specified in the TSP’s tariff or the general terms and conditions.
A TSP with tariff-based gas quality provisions should post information related to such provisions that:
a.are representative of mainline gas flow for that TSP: and
b.are routinely available in electronic format for its representative mainline locations.
Such information should be reported in units as specified in the tariff or general terms and conditions. TSP’s may agree with their Service Requesters that information related to certain tariff-based gas quality provisions does not need to be posted.
Upon mutual agreement between the TSP and its Service Requesters, the TSP should post additional electronically available gas quality attribute information that is representative of mainline gas flow.
Discussion - NAESB WGQ Standard No. 4.3.92
Proposed changes to NAESB WGQ Standard 4.3.92 are inappropriate since download processes typically do not allow customized data requests prior to the download of data. Typically, a download provides all of the data and then it is the responsibility of the party downloading the data to extract and retain the data needed for their processes. Additionally, NAESB WGQ Standard No. 4.3.16 is the only standard other than 4.3.92 that deals with download processes and it specifies only the use of the format for the Index of Customers as prescribed by FERC requirements. We recommend that proposed changes to NAESB WGQ Standard 4.3.92 be rejected. The existing standard does not require modification and should continue to read as follows:
NAESB WGQ Standard No. 4.3.92
Data provided pursuant to NAESB WGQ Standard No. 4.3.90 should be provided in a tabular downloadable file to be described by the Transportation Service Provider. The first row of the file should contain the column headers.
Discussion - Proposed NAESB WGQ Standard No. 4.3.x1
Proposed NAESB WGQ Standard No. 4.3.x1 would require pipelines to post a gas quality attribute (Wobbe Number) which is not included in their tariffs or terms and conditions. Such a requirement is out of step with other NAESB WGQStandards that continually reference the tariff or terms and conditions as the source for specific operating requirements (see NAESB WGQ Standard No. 2.3.61 which states in part “In the event of a conflict between this standard and the Transportation Service Provider’s existing tariff or terms and conditions, the latter will prevail”). Secondly, posting a gas quality attribute not included in the tariff or terms and conditions provisions could lead to the inappropriate conclusion that said attribute is being actively monitored and/or utilized by the pipeline and that no monitoring or equipment is needed by customers sensitive to specific concentrations of the gas stream. To eliminate these concerns a structure similar to the wording of proposed standard 4.3.x2 is proposed. We recommend that 4.3.x1 be modified to read as shown below.
Pipeline Segment Revised Proposed NAESB WGQ Standard No. 4.3.x1
For data provided pursuant to NAESB WGQ Standard 4.3.90, a Transportation Service Provider (TSP), upon notification from a customer or other applicable party of its desire to begin discussing the interchangea bility of gas supplies, should endeavor to calculate a Wobbe Number for location(s) that are representative of mainline gas flow. As soon as practical, but no later than the initiation of discussions to develop with tariff-based gas quality interchangeability provisions, a TSP should provide post a Wobbe Number for the location(s) that are representative of mainline gas flow. Where a TSP uses an alternative method to characterize interchangeability, it may substitute or supplement the Wobbe Number with the applicable data. Where no above-mentioned notification is received by the TSP or where the above mentioned discussions lead to a conclusion that tariff based gas quality interchangeability provisions are not necessary, a TSP may satisfy this standard by providing a Heating Value and Specific Gravity.
Discussion - Proposed NAESB WGQ Standard No. 4.3.x2
The Pipeline Segment proposes the three minor changes as shown below:
- addition of the word "liquid"
- addition of the word "the"
- and making the word ‘dropout’ as 2 words to be consistent with other documents in the industry
Pipeline Segment Revised Proposed NAESB WGQ Standard No. 4.3.x2
For data provided pursuant to NAESB WGQ Standard No. 4.3.90, a Transportation Service Provider (TSP) with tariff-based gas quality provisions for the control of hydrocarbon liquiddrop out should measure or calculate a 1) Cricondentherm Hydrocarbon Dew Point (CHDP) or 2) C6+GPM for the locations(s) that are representative of mainline gas flow. If applicable, the TSP should provide the control parameter specified within its tariff. Where a TSP uses an alternative approach to control hydrocarbon liquid drop out, it may substitute the appropriate control parameter.
Standards-Clean Version
Pipeline Segment Revised NAESB WGQ Standard No. 4.3.90
The Transportation Service Provider (TSP) should provide on its Informational Postings Web Site daily average gas quality information for prior gas day(s), to the extent available, for location(s) that are representative of mainline gas flow. The information should be provided in a downloadable format. In any event, all applicable parties’ compliance with gas quality requirements is in accordance with the TSP’s tariff or general terms and conditions.
Listed below are examples of gas quality attributesthat could be included in the posting for the applicable Gas Day(s) and Location(s):
•Heating Value
•Interchangeability index(ices)/factor(s)
•Hydrocarbon liquid drop out control parameter(s)/factor(s)
•Hydrocarbon components, % of C1 – Cnn, as used in determining Heating Value
•Specific Gravity
•Water
•Nitrogen
•Carbon Dioxide
•Oxygen
•Hydrogen
•Helium
•Total Sulfur
•Hydrogen Sulfide
•Carbonyl Sulfide
•Mercaptans
•Mercury and/or any other contaminants being measured
•Other pertinent gas quality information that is specified in the TSP’s tariff or the general terms and conditions.
A TSP with tariff-based gas quality provisions should post information related to such provisions that:
- are representative of mainline gas flow for that TSP; and
- are routinely available in electronic format for its representative mainline locations.
Such information should be reported in units as specified in the tariff or general terms and conditions. TSPs may agree with their Service Requesters that certain tariff-based gas quality provisions do not need to be posted.
Upon mutual agreement between the TSP and its Service Requesters, the TSP should post additional electronically available gas quality attribute information that is representative of mainline gas flow.
Pipeline Segment Revised Proposed NAESB WGQ Standard No. 4.3.x1
For data provided pursuant to NAESB WGQ Standard 4.3.90, a Transportation Service Provider (TSP), with tariff-based gas interchangeability provisions, should post a Wobbe Number for the location(s) that are representative of mainline gas flow. Where a TSP uses an alternative method to characterize interchangeability, it may substitute or supplement the Wobbe Number with the applicable data.
Pipeline Segment Revised Proposed NAESB WGQ Standard No. 4.3.x2
For data provided pursuant to NAESB WGQ Standard No. 4.3.90, a Transportation Service Provider (TSP) with tariff-based gas quality provisions for the control of hydrocarbon liquid drop out should measure or calculate a 1) Cricondentherm Hydrocarbon Dew Point (CHDP) or 2) C6+GPM for thelocations(s) that are representative of mainline gas flow. If applicable, the TSP should provide the control parameter specified within its tariff. Where a TSP uses an alternative approach to control hydrocarbon liquid dropout, it may substitute the appropriate control parameter.